Get ready for pricing wars
Thursday, April 28th, 2011
A good article by Stan Soloway on measures being taking by DoD to increase its ability to dictate price reasonableness, and drive up the cost of doing business with the Government.
Tim
Click here for a copy of the article
Federal Acquisition Circular 2005-50 – Ten Interim and Final FAR rules that impact most contractors
Wednesday, March 16th, 2011
Attached is a copy of the Federal Acquisition Circular 2005-50 publishing interim and final rules effecting everyone.
The first rule of concern is “Proper Use and Management of Cost-Reimbursement Contracts (Interim)” significantly increases the threshold for COs to justify the use of Cost-Reimbursement contracts over fixed priced contracts. Expect to see contracts that would in the past be issued and Cost-Reimbursement to be issued as fixed price. This will significantly increase the risk on contractors.
The second rule of concern is “Requirements for Acquisition Pursuant to Multiple-Award Contracts (interim)” – Raises the bar on competitive requirements for the issuance of such contracts.
The third is “Disclosure and Consistency of Cost Accounting Practices for Contracts Awarded to Foreign Concerns” This final rule brings the FAR into compliance with the CAS on disclosure requirements for foreign concerns that did not exist before. Foreign concerns with CAS covered contracts must now be compliant with CAS 401 and this requirement is no included in FAR 52.230-4
I have highlighted sections of the FAC that may be of interest to you
Tim
Click here for a copy of the FAC 2005-50
Another example of the Idiocy call guidance to DCAA auditors
Wednesday, March 2nd, 2011
Below is one of the best examples of government double speak and CYA that I have seen in a long time. This statement allows DCAA to site the contractor for a system deficiency while also taking advantage of the cost saving when a contractor reduces it rates to be competitive.
DCAA Technical Advice
Recent advice for a DCAA Regional Technical Programs Specialist regarding a contractor’s decision not to invoice for the fully allowable indirect cost rates:
“The voluntary underbilling should be cited as a [system] “(b) … In establishing billing rates, the contracting officer (or cognizant Federal agency official) or auditor should ensure that the billing rates are as close as possible to the final indirect cost rates anticipated for the contractor’s fiscal period, as adjusted for any unallowable costs.” (Emphasis added) If a contractor does not anticipate invoicing the fully allowable amount, the contractor’s actions would not violate the wording of the provision. deficiency.”
